Global Applicant and Candidate Privacy Policy
Welcome to HoYoverse. At HoYoverse, we value your trust and are committed to protecting your personal information throughout the application and candidate selection process. "We" or "HoYoverse" means Cognosphere Pte. Ltd., headquartered in Singapore, and its affiliates and subsidiaries.
This Privacy Policy has been prepared to explain how we collect, use, disclose, and safeguard your personal data during your job application process with us, including any personal data submitted through our careers or recruitment websites, appointed recruitment agencies, employee referrals, as well as our online and offline recruitment activities. This Policy covers recruitments and applications for positions with HoYoverse, including employees, internship, outsourcing and contractor positions. This Policy will also cover candidates whom we find suitable for our open positions based on publicly available profiles, as well as candidates who begin their pre-onboarding process, before they officially join us.
We encourage you to carefully review this Privacy Policy to understand how and why we are using Personal Data about you and what your rights are under the relevant privacy laws.
1. Personal Data about you
"Personal Data" is any information about you or your household, as well as a combination of pieces of information that could reasonably allow you or your household to be identified.
We may collect the following categories of Personal Data from you:
Identification and similar information including name, gender, age, date of birth, email address, home address, contact details, photographs, demographic information, citizenship, nationality, marital status, date of marriage, dependent names, relationship, age or date of birth, domicile or residence data.
Educational and professional details including but not limited to highest education, certifications, previous employment history with all supporting documents and proof, and/or personal portfolio containing your previous works.
Past or current compensation and benefits information including details of last drawn salary and benefits, salary reviews and leave entitlement.
Financial information, such as your bank account information, your tax withholding information, and credit checks (where applicable).
information collected as part of the interview process, such as notes taken from your interview(s) or information provided by your represented recruitment agency (if applicable);
Information about your performance at work, including references obtained from third parties such as your previous colleagues, supervisors, and clients ("Referees").
Your information from publicly available sources, including online, that we believe is relevant to your application or a potential future application (e.g. your LinkedIn profile).
Learning and development information including training, certifications, attendance & and assessment records of past or present engagements.
Internet or other electronic network activity information, such as browsing history, Internet Protocol address, search history, and information regarding an applicant's interaction with Company electronic resources, websites, application, or other online services, as well as physical and network access logs and other network activity information related to your use of any Company electronic resources;
Audio, video and other electronic data, such as audio, electronic, visual, or similar information, such as CCTV footage, photographs, and call recordings and other audio recording (e.g., recorded meetings and webinars)
Other information you create or provide, such as the content you create, upload, or otherwise provide in connection with the application and recruitment process.
Where permitted by applicable law and/or where you have provided any consent required by applicable law, the Personal Information we collect may include information that falls into one or more of the following categories of "Sensitive Personal Data":
government-issued or tax identification numbers, as part of your identity information;
race or ethnic origin, or information we incidentally receive as part of your identity documents or information processed for the purpose of applicant diversity monitoring;
religious beliefs, affiliations, or philosophical beliefs, in the event that we are able to accommodate and support specific religious needs (eg prayer rooms, specific diets);
membership in a professional or trade association or membership in a trade union, for example, where contributions to such organisations are legally mandated;
health, age and disability, for the purposes of making reasonable adjustments to the workplace in order to facilitate job interviews or information relating to infectious disease control.
genetic or biometric data, in order to facilitate your entry to some of our premises; and/or
criminal records such as suspicions, prosecutions, allegations or convictions of criminal offences where necessary to protect HoYoverse’s interest and legal compliance.
We do not knowingly collect information from minors under 16 years of age.
It is important to understand that in accordance with applicable laws, we may be obligated to collect certain data. Failure to provide us with this information may hinder our ability to fulfill these legal obligations. Consequently, this may impact your candidacy and suitability for the position being offered.
We encourage you to contact us to update or correct your information if it changes or if the personal data we hold about you is inaccurate. If you wish to update your personal data with us, you may reach out toour Recruitment team, or our Data Protection Office in the ‘Contact Us’ section below. For any specific application, we may not be able to facilitate changes to the documents provided once they have been submitted. However, you may at any time withdraw your application and request deletion of your information.
Sources of personal data
Your Personal Data may be collected directly from you or indirectly through our authorized third-party service providers, who are authorized to collect such information. It may also be obtained from your Referees or from your publicly available profiles, such as your LinkedIn profile. If you access our career or recruitment pages, we may also automatically collect data using technologies like cookies, browser web storage, and data caches. If you attend our office Premises for interviews, we may also have surveillance and recording technologies employed to the extent permissible under local laws.
We understand the significance of your awareness and control when it comes to the processing of your personal information. We are committed and will do our best to promptly inform you in the event that we receive your personal data from another source other than directly from you. Should you become aware that we are processing your personal data without your knowledge, we kindly request that you inform us. Your feedback is crucial to maintaining the integrity of our processes. At your discretion, you may choose to proceed with your application or withdraw it, and we will take immediate action to address the situation and improve the process with the relevant parties.
2. Purpose of processing Personal Data
We collect, use and disclose Personal Data about you for the following purposes.
Administrative purposes to carry out the application and recruitment process, such as:
(i) Assessing your skills, qualifications and interests against our career opportunities.
(ii) Communications with you about the recruitment process and/or your application(s), including, in appropriate cases, informing you of other potential career opportunities at other HoYoverse Companies.
(iii) Verifying your information and carrying out reference, background, sanctions and other application screening checks as part of your application.
(iv) Where it is necessary in order for us to take steps prior to our potentially entering into a contract of employment with you.
(v) For recordkeeping purposes, such as to demonstrate your agreement to, or acceptance of, documents presented.
(vi) Where requested by you, assisting you with obtaining an immigration visa or work permit where required.
(vii) Where necessary, we may process Sensitive Personal Data relating to your health, or limitations, special abilities in order to comply with our health and safety and occupational health obligations, for providing insurance based on your eligibility where applicable or to consider how your health affects your ability to do your job and whether any adjustments to your job might be appropriate.
To create a talent pool for future job openings
(i) Conducting research on publicly available platforms, or your previously unsuccessful application, to consider your educational and professional background and skills, and to contact you if we think you would be suitable for a role with a member of the HoYoverse group of companies.
Security and other legal obligations, such as:
(i) Protecting against security threats, abuse, illegal activity, and violations protect the safety and security of visitors to our web sites or other properties.
(ii) Protecting against fraud or other illegal activity or for risk management purposes.
(iii) Emergency situations where the health or safety of one or more individuals may be endangered.
(iv) Protecting our rights and property, our users, applicants, candidates, employees or the public as required or permitted by law.
(v) Defending against any potential legal claims or regulatory action.
(vi) Enforcing our terms of use and any other policy on this Site.
(vii) Creating and/or submitting reports as required under any local laws and/or regulations, where applicable.
(viii) Complying with applicable laws, regulations, legal processes or responding to legally enforceable governmental requests.
For the purposes of enhancing our practices and systems, such as
(i) Making improvements to our application and/or recruitment process.
(ii) Ensuring diversity and inclusion.
(iii) To continuously enhance the functionality and performance of our websites and technologies.
We will only use Personal Data about you for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use Personal Data about you for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Personal Data you provide us
Apart from your Personal Data, we may also request that you provide us with Personal Data of:
your family members for administrative processing purposes, such as indicating them as your emergency contacts, assisting with their immigrations visa applications or administration of benefits, where applicable.
Your Referees, in order to contact them to conduct reference checks.
Before you provide such person’s Personal Data to us, you must first seek their consent to provide such Personal Data and inform them of the processing to be carried out by us, as detailed in this Policy. You shall warrant and represent that you have obtained such person’s consent prior to providing any such Personal Data to us.
Technologies and Automated decision making
We want to assure you that our recruitment processes do not rely on any automated decision-making. While we may employ technology, such as Optical Character Recognition (OCR), to assist in the processing of candidate personal data, our decisions are not based on automated algorithms. Human review and consideration are integral to our evaluation and selection procedures. We strive to ensure that our use of technology-assisted tools, complements our assessment by enhancing efficiency and accuracy. Ultimately, our goal is to make informed decisions based on a holistic evaluation of a candidate's qualifications and suitability for the positions we offer.
3. Who we may share Personal Data with
Personal Data about you may be shared with our group company employees, staff, contractors, third party vendors who have a business need to access such Personal Data and may include human resources personnel, hiring teams, our background check vendor partners, benefits partners and/or their respective designees.
Due to the global nature of our organization and operations, your personal data, including sensitive personal data may be transferred to, stored, and processed outside of the country in which you reside in, or the country where the position you have applied for is located, or Singapore, where HoYoverse is headquartered. This country may be a country that is not regarded as ensuring an adequate level of protection for personal information. We have put in place appropriate safeguards (such as contractual commitments or recognized certifications) in accordance with applicable legal requirements to ensure that your data is adequately protected.
Most of the organizations we transfer your personal data to act as data processors on our behalf, following our instructions. However, in certain cases, these organizations may also act as separate data controllers with their own data protection policies. They will be responsible for ensuring compliance with applicable data protection laws, including providing you with the necessary notifications on how they will process your personal data.
If you are represented and referred to us by a recruitment agency, we may be required to share certain information about your application and offer package with them, where they will independently handle your data as a separate data controller.
In certain circumstances during our application and recruitment process, we (directly or through our background check vendors) may need to transfer your personal data to Referees provided by you. This transfer is necessary to assess your skills, qualifications, and suitability for the position applied for. We will only share the minimum necessary information with the referees to obtain their professional opinion and assessment. It is important to note that we will take reasonable measures to ensure the confidentiality and security of your personal data during the transfer process, and will not disclose details of your offer package with your referees. By providing us with the contact information of your referees, you acknowledge and consent to the transfer of your personal data to them for the purposes outlined above.
To comply with our statutory and other obligations and for the proper management of our business operations, our service providers or our customers, we may also provide information to other third parties, including, but not limited to, auditors, accountants, lawyers and other professional advisers, as well as to administrative authorities, courts, law enforcement and/or regulatory authorities, arbitrators, experts, adverse parties and/or their advisors.
In certain circumstances, we may engage in corporate transactions, such as mergers, acquisitions, reorganizations, or asset sales. During such transactions, information may be transferred or accessed to facilitate the assessment and completion of the transaction. In the event of a business or asset sale, Personal Data may be transferred to third parties involved in the transaction. We will take appropriate measures to ensure the confidentiality and security of your Personal Data during such transactions.
4. Period of retention
If you apply for a position with HoYoverse, and your application is not successful (regardless of whether it was your decision or ours), we will retain your Personal Data for a period of time after your application. We will retain your personal data for the purposes described above. We are committed to retaining your data for only as long as necessary and in a manner that aligns with the purposes described above. We will ensure that the retention period is proportionate and based on your consent, if applicable, as well as in compliance with our legal and regulatory obligations.
If you do not want us to retain your information for consideration for other roles, or want us to update it, please contact our data protection office, or inform any members of our Recruitment team.
In some circumstances, we may use your Personal Data to create deidentified and/or statistical information, which will no longer be associated with you.
5. Your rights
You may have certain legal rights regarding your personal data. These include the rights to:
access your personal data
rectify the information we hold about you
erase your personal data
restrict our use of your personal data
object to our use of your personal data
receive your personal data in a usable electronic format and transmit it to an external third party (right to data portability)
We strive to ensure that you can exercise your rights effectively and with ease. Please be aware that the extent or implementation of these rights may be subject to certain legal requirements, including the laws applicable to your specific situation. Our commitment is to work within the framework of local laws and regulations while providing you with the necessary support to exercise your rights to the fullest extent possible.
If you would like to discuss or exercise such rights, please contact us. In certain circumstances, we may need additional information from you in order to verify your identity or fulfil your request. This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We also aim to provide access to your personal information without charging a fee. However, in exceptional cases where your request for access is deemed unfounded or excessive, we may apply a reasonable fee. We will communicate promptly when the need arises, and ensure they are proportionate and in line with legal requirements.
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to your local data protection authority.
6. Contact us
We have established a data protection office to oversee compliance with this Policy. You may contact our data protection office at privacy@hoyoverse.com for any of the following reasons:
To exercise your rights under section 6 above;
To lodge a complaint with us; or
If you have any queries about this Policy.
7. Jurisdiction Specific Supplemental Terms
We strive to respect the privacy rights of individuals in all jurisdictions. However, certain jurisdictions have specific legal requirements requiring us to specifically notify, address and disclose how we handle, process and protect individuals’ personal data. If your jurisdiction is not listed, please note that it does not diminish our commitment to respecting your privacy rights.
European Union
If you are in the European Union, we must communicate to you our specific legal basis to process your personal information. In most cases the legal basis will be one of the following:
To fulfil our contractual obligations to you, for example to facilitate your application and onboarding process. Failure to provide this information may prevent or delay the fulfilment of these contractual obligations.
To comply with our legal obligations, for example obtaining proof of your identity to enable us to ensure that we fulfil our necessary labour, tax, pension or benefits related obligations required by your local law.
For our and/or a third party’s legitimate interests. When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms. An example of legitimate interests is, to ensure the security of the Personal Data entrusted to us, or to understand how you use our platforms, and our diversity efforts, in order for us to derive knowledge from that. This allows us to improve our technologies and recruitment processes.
To comply with applicable laws, including immigration and/or employment laws and regulations
For the performance of a task in the public interest where these are not overridden by your interests or fundamental rights and freedoms, including where HoYoverse is subject to national or EU measures put in place by public health and other regulatory authorities
We will obtain your express consent to collect and use certain types of personal information when we are required to do so by law (for example, in relation to our direct marketing activities, Cookies and Tracking Technologies or when we process special categories of personal data. If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us at privacy@hoyoverse.com.
Some of the third parties we may share your Personal Data with may be located in countries outside of the European Economic Area ("EEA"), United Kingdom ("UK") and other regions deemed by the European Commission to have provided adequate protection for personal data ("Adequate Regions"). For transfers outside these Adequate Regions, HoYoverse takes various measures to ensure your personal data is adequately protected, including that such international transfers will be made subject to the appropriate EU Standard Contractual Clauses adopted by the European Commission, as updated from time to time, or other such data transfer mechanism recognised by the European Commission.
United Kingdom
If you are in the United Kingdom, we must communicate to you our specific legal basis to process your personal information. In most cases the legal basis will be one of the following:
To fulfil our contractual obligations to you, for example to facilitate your application and onboarding process. Failure to provide this information may prevent or delay the fulfilment of these contractual obligations.
To comply with our legal obligations, for example obtaining proof of your identity to enable us to ensure that we fulfil our necessary labour, tax, pension or benefits related obligations required by your local law.
For our and/or a third party’s legitimate interests. When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms. An example of legitimate interests is, to ensure the security of the Personal Data entrusted to us, or to understand how you use our platforms, and our diversity efforts, in order for us to derive knowledge from that. This allows us to improve our technologies and recruitment processes.
To comply with applicable laws, including immigration and/or employment laws and regulations
For the performance of a task in the public interest where these are not overridden by your interests or fundamental rights and freedoms, including where HoYoverse is subject to national or EU measures put in place by public health and other regulatory authorities
We will obtain your express consent to collect and use certain types of personal information when we are required to do so by law (for example, in relation to our direct marketing activities, Cookies and Tracking Technologies or when we process special categories of personal data. If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us at privacy@hoyoverse.com.
United States of America - California
If you are a resident of California, the California Consumer Privacy Act ("CCPA") will apply to you. This addendum ("Addendum"), which should be read together with the Policy, is added to help you understand how we handle your information to comply with the CCPA.
Your rights under the CCPA:
Right to Know – You have the right to know what Personal Data we have collected, used, disclosed, and shared about you, including (i) the specific pieces of Personal Data we have collected about you; (ii) the categories of Personal Data we have collected about you, (iii) the categories of sources from which we collect information about you; (iv) the business or commercial purposes for which we collect information about you, and (v) the categories of third-parties with whom we share or have shared Personal Data about you. You have the right to access Personal Data about you in a portable, and, to the extent technically feasible, readily usable format but no more than twice in a twelve (12) month period.
Right to Correct – You have the right to correct inaccuracies in Personal Data about you, taking into account the nature of the Personal Data and the purposes of the processing.
Right to Delete – You have the right to request that we and our services providers delete Personal Data that we have collected from you. We will endeavour to fulfil any verifiable requests for deletion, unless an exception under the CCPA applies.
Right to Opt-Out – while you have the right to opt-out of an organisation selling or "sharing" Personal Data about you. "Sharing" refers specifically to sharing for cross-context behavioral advertising, which is the targeting of advertising to a consumer based on the consumer’s Personal Data obtained from the consumer’s online activity across numerous websites. HoYoverse does not sell, rent or "share" Personal Data about you, as defined and restricted under the CCPA.
Right to Limit – You can direct us to only use your Sensitive Personal Data for limited purposes, such as to only provide you with the services you requested.
Right to Non-Discrimination – You have the right not to be discriminated against if you exercise your rights under the CCPA. Unless otherwise permitted, we will not (i) deny you good or services, (ii) charge you a different price or rates for good or services, or (iii) provide you a different level of quality of good or services.
If you have questions or concerns related to your rights under CCPA, or would like to exercise your rights, you may contact us at privacy@hoyoverse.com.
Last updated: 4 July 2023